Legal

Wispim — Privacy Policy

Version 1.1 · Effective date: 3 September 2026

1. Who we are (Controller)

Wispim is a teleprompter app for iPhone published by Evgeny Savochkin, a sole proprietor (jednoosobowa działalność gospodarcza) established in Poland (Polska), trading as Onwards (bundle namespace com.onwards).

  • Address: Aleksandra Gieysztora 4/97, 02-999 Warszawa, Polska
  • Email: support@wispim.com
  • NIP: 9512576713 · REGON: 526236847 · Registered in CEIDG (Centralna Ewidencja i Informacja o Działalności Gospodarczej)

The developer is the administrator danych osobowych (data controller) for the limited processing described below.

2. Our privacy approach

Wispim is built to keep your data on your device. There are no user accounts. Your scripts are stored only on your device as local JSON files and are never uploaded to us. We do not sell your data, we show no ads, and we do not track you across apps or websites.

3. What data is processed, and why

(a) Scripts and app content — stays on device. Scripts, imported documents and app settings are stored locally on your device. We never receive, store or transmit them.

(b) Microphone and speech recognition. The microphone is used only for voice-following scroll modes. Speech recognition uses Apple’s SFSpeechRecognizer:

  • Where the language supports on-device recognition, transcription happens entirely on your device.
  • Otherwise, iOS sends audio to Apple’s servers to be processed under Apple’s terms. Server-based recognition is subject to a limit of about one minute per request. When this happens, iOS shows a system alert: “Speech data from this app will be sent to Apple to process your requests. This will also help Apple improve its speech recognition technology.”
  • Wispim itself never stores or transmits your audio or transcripts. Any server-based processing is performed by Apple as an independent controller under Apple’s own privacy policy. Legal basis: performance of the app functionality you request / your consent to microphone and speech use (GDPR Art. 6(1)(b)/(a)).

(c) Analytics (TelemetryDeck). We use privacy-first analytics from TelemetryDeck GmbH, Von-der-Tann-Str. 54, 86159 Augsburg, Germany, acting as our processor (podmiot przetwarzający) under Art. 28 GDPR. Data is stored exclusively in the EU. Identifiers are anonymised on your device by a double salted hash and hashed again on ingestion; TelemetryDeck sets no cookies and performs no cross-app tracking. Legal basis: our legitimate interest in understanding and improving the app (GDPR Art. 6(1)(f)).

4. Analytics events we send to TelemetryDeck

We send the following events (with the listed, non-identifying parameters):

  • session_started
  • onboarding_completed
  • attribution_answered (source, optional free text)
  • prompter_started (mode, floating, backend)
  • following_stalled (mode, language, onDevice, seconds, wordsInScript bucketed)
  • mic_recovery (attempt, success)
  • paywall_shown (trigger)
  • purchase (product id)
  • language_auto (locale)
  • file_imported (format, bucketed word count)
  • file_import_failed (format)
  • voice_command (name, mode)
  • review_prompted (isPro, completedSessions)
  • test_signal

Plus the SDK’s automatic signals: session start, new-install detection, together with device model and OS version.

No script text, transcripts, file names or audio are ever sent.

5. Purchases

Purchases are made through Apple StoreKit: auto-renewable subscriptions (monthly, yearly) and a one-time lifetime purchase. Apple Distribution International Ltd. (Cork, Ireland) is the seller/merchant of record; your purchase, billing data and refunds are handled by Apple under Apple’s terms and privacy policy. We receive only anonymised, aggregate purchase-event analytics (see §4). No ads.

6. File import

You may optionally import files (PDF, DOCX, RTF, TXT, MD). Import is processed locally on your device; imported content is not sent to us. An offline open-source library (ZIPFoundation) is used only to read Word documents on the device; it makes no network connections and sends no data anywhere.

7. Support

If you email support, we process your email address and message content to answer you (GDPR Art. 6(1)(b)/(f)). You may voluntarily attach a diagnostic log; that log contains no script text and no audio.

8. Retention

  • On-device data remains until you delete it or uninstall the app.
  • Support emails: kept for as long as needed to handle your request and for a reasonable follow-up period of 12 months.
  • Analytics: retained by TelemetryDeck in anonymised form per its data-processing terms.

9. Recipients and third parties

We use no third-party analytics, advertising or tracking SDKs other than TelemetryDeck. An offline open-source library (ZIPFoundation) is used only to read Word documents on the device; it makes no network connections and sends no data anywhere. Apple acts as an independent party for App Store purchases and for any server-based speech recognition.

10. International transfers

Analytics data is stored exclusively in the EU. Where Apple processes audio for server-based speech recognition, Apple may transfer data internationally under its own safeguards (GDPR Arts. 44–49).

11. Your rights

Under the GDPR (Arts. 12–22) and the ustawa z dnia 10 maja 2018 r. o ochronie danych osobowych you have the rights of access, rectification, erasure, restriction, portability and objection, and the right to withdraw consent at any time. Because we operate without accounts and cannot identify you from the anonymised analytics, Art. 11 GDPR may apply — we may be unable to link that data to you, and may ask for additional information to act on a request. To exercise a right, email support@wispim.com.

You may lodge a complaint with the supervisory authority: Prezes Urzędu Ochrony Danych Osobowych (UODO), ul. Stawki 2, 00-193 Warszawa, uodo.gov.pl.

12. Children

Wispim is a general-audience app and is not directed at children under 13. Consistent with COPPA (16 CFR §312.2), it is intended for a general audience and we do not knowingly collect personal data from children under 13.

13. California notice (voluntary)

We do not sell or share personal information as defined by the CCPA/CPRA. We are below all CCPA thresholds — for the 2026 compliance year these are annual gross revenue over $26,625,000 (CPI-adjusted from $25,000,000 per the California Privacy Protection Agency’s 17 December 2024 announcement), buying/selling/sharing the personal information of 100,000+ California consumers or households, or deriving 50%+ of revenue from selling/sharing personal information. This notice is provided voluntarily.

14. UK users

For users in the UK, the UK GDPR applies as retained/assimilated law; you may contact the Information Commissioner’s Office (ICO), ico.org.uk. Our practices are the same as described above.

15. Changes

We will update this policy as needed and bump the version number and effective date.

16. Controlling language

This Privacy Policy is published in English, Polish, German and Russian. The English version controls in case of conflict, except that for consumers resident in Poland the Polish version prevails where mandatory Polish consumer law or the Act on the Polish Language (ustawa o języku polskim) so requires.

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